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PSD3 and PSR: It’s Never Too Early to Start Getting Ready (Part 1)

  • Writer: Sigita Zavišienė
    Sigita Zavišienė
  • May 6
  • 2 min read

Updated: Jun 8


Agreed final text of payments package (3rd Payment Services Directive (“PSD3”) and the Payment Service Regulations (“PSR”) was published on 23rd April 2026 and awaits final approval.


Overview


  • Regulatory frameworks on payment services and e-money will be blended into one single regulatory framework.

  • PSD2 and EMD2 will be replaced by PSD3 and PSR, the very first payment services regulation.

PSD3 authorisation PSR regulation EU payment institution capital requirements PSD2 replacement EMI PSD3 transitional period payment services 2026 PSD3 vs PSR difference

  • PSD3 will need to be transposed into national laws regulating payment services.

  • SR will be directly applicable without need for implementation at national level.

  • The main aim of the proposed PSR is to provide for further harmonization of the existing requirements regulating the payment services industry in the EU.


The Changing Regulatory Perimeter

 

PSD3

WHO?

PSR

WHAT?

Licensing and authorisation of the PSPs

Scope & Exclusions

Supervision of the payment institutions

Obligations of the PSPs

Cooperation between NCAs

Transparency requirements and Consumer Protection

PI and EMI merged

Enhance liability framework for fraud.

 

Revised Initial Capital Requirements


  1. Money remittance services only: increased from EUR 20,000 to EUR 40,000.

  2. Payment initiation services: remain unchanged at EUR 50,000.

  3. Other payment services listed in Annex I, points 1–5: increased from EUR 125,000 to EUR 150,000.

  4. Issuance of e-money only: EUR 250,000.


Where a PSP issues e-money and also provides other payment services, the relevant minimum initial capital amounts must be added together.


As a result, for a current EMI providing payment services in addition to issuing e-money, the minimum initial capital requirement would be at least EUR 400,000, compared with EUR 350,000 today.


Transitional Period – 27 months

 

Payment institutions and e-money institutions that are already authorised will be allowed to continue providing their authorised payment services during the transitional period.


They will not need to apply for a new PSD3 authorisation immediately and will not need to fully comply with the new requirements until 27 months after PSD3 enters into force.


Automatic authorisation may be possible where the competent authorities have evidence that the institutions already comply with the relevant requirements under PSD3.


21-Month Implementation Timeline


Member States have 21 months from PSD3’s entry into force to adopt and publish national implementing laws.


The PSR will become applicable 21 months after its entry into force.


Need advice on PSD3/PSR requirements? Contact for services: Sigita Zavišienė

 

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